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HMRC internal manual

Double Taxation Relief Manual

USA: Double taxation agreement, Article 6: Income from real property

  1. Income derived by a resident of a Contracting State from real property, including income from agriculture or forestry, situated in the other Contracting State may be taxed in that other State.
  2. The provisions of paragraph 1 of this Article shall apply to income derived from the direct use, letting, or use in any other form of real property.
  3. The provisions of paragraphs 1 and 2 of this Article shall also apply to the income from real property of an enterprise.